April 2014 Spray 25 whatsoever (e.g. Excepted Quantities – E Label) and will not be deliverable otherwise. This clearly poses a problem, because the DOT no longer recognizes this marking and my client may be subjected to a fine of $75,000 if they use this instead of the current marking, which is required by the DOT. Consumer Commodities USPS Pub. 52 still, unfortunately, recognizes the use of the ORM-D-AIR marking for certain hazardous materials offered for transport by domestic air mail, even though the DOT banned it in January 2013. USPS Pub. 52, section 343.3a states, for example, that “... for air transportation, parcels containing mailable Class 3 materials must be plainly and durably marked on the address side with ‘ORM-D AIR’ immediately following or below the proper shipping name (e.g., Consumer Commodity). A properly completed shipper’s declaration for dangerous goods prepared in triplicate must be affixed to the outside of the mailpiece.” This clearly puts any shipper in a difficult position that may subject them to a DOT civil penalty of up to $75,000, even though they may be in full compliance with USPS Regulations. Therefore, I will restate and strongly re-emphasize what I stated in last month’s article. The USPS states in Pub. 52, Section 323 that “full responsibility rests with the mailer to comply with all Postal Service and non–Postal Service laws and regulations in the mailing of hazardous material (DMM 601.10.5). Anyone who mails, or causes to be mailed, a nonmailable or improperly packaged hazardous material can be subject to legal penalties (i.e., fines and/or imprisonment), including but not limited to those specified in 18 U.S.C.” The USPS states in the International Mail Manual (IMM), § 131.4 that “regardless of any statement in this manual or the statement of any employee of the U.S. Postal Service, the burden rests with the mailer to ensure compliance with domestic, international, and individual country rules and regulations for mailability.” I will also re-emphasize that shippers are most strongly advised to consult with the USPS before considering offering dangerous goods by mail. Copies of the USPS publications referred to in this article may be obtained by contacting the author or from the following URL’s: • Domestic Mail Manual: http://pe.usps.gov/text/dmm300/dmm300_landing.htm • International Mail Manual: http://pe.usps.com/text/imm/welcome.htm • USPS Publication 52: http://pe.usps.com/text/pub52/welcome.htm Spray
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